AML/KYC Policy

Our Money Laundering and Terrorist Finance Prevention Policy

It is the policy of Magebox Entertainment LTD. to prohibit and actively prevent money laundering, and any activity that facilitates money laundering or the funding of terrorist or criminal activities.

These Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF) policies, procedures and internal controls are intended to ensure compliance with all applicable regulations.

The AML program of www.dejen.com is designed to be compliant with:

• EU : Directive 2015/849 of the European Parliament and of The Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering
• EU : Regulation 2015/847 on information accompanying transfers of funds
• EU : Various regulations imposing sanctions or restrictive measures against persons and embargo on certain goods and technology, including all dual-use goods
• BE : "Law of 18 September 2017 on the prevention of money laundering limitation of the use of cash

Our operating rules are as follows:

• Dejen does not accept cash purchases or cash redemptions in any cases.
• Dejen does not permit any redemptions unless such purchase was occasioned by accident or mistake. Additional documentation is required to establish the existence of an accident or mistake.
• Dejen does not accept any third parties' purchases on the user's account, managing the account on behalf of somebody, joint or shared accounts, etc.
• Dejen does not allow any exceptions in the field of documentation required from users.
• Dejen does not allow peer to peer transfers.
• Dejen reserves the right to refuse to process the User's transaction at any time, in case of suspicion of AML risk.
• In accordance with the international law, we are not obliged (or even forbidden) to inform our clients, if we report their behavior as suspicious to relevant authorities.

Customer Due Diligence Program

Dejen has established standards regarding Know-Your-Customer ("KYC"). We make reasonable efforts to verify your identity, including heightened identification requirements when appropriate, geographical data, and user provided data. As KYC does not involve static data, but dynamic data through the relationship with the customer, it also needs follow-up and ongoing monitoring of the customer. We reserve the right to deny access to our platform if there is insufficient proof of ownership or identity, and activity suspected to be deliberately fraudulent will be reported. We apply all reasonable measures to detect attempts to use our platform by sanctioned individuals or organisations; any attempts as such will be reported to the Financial Intelligence Unit as soon as reasonably practicable and without undue delay.

Where we consider a customer to be a high-risk person, as defined by the Financial Action Task Force, we may request additional information as part of our Enhanced Due Diligence regime, in order to establish the veracity of their person and prevent access to our platform by those under financial sanction, or with malign intent. This includes: persons considered to be Politically Exposed Persons (PEPs), the family members of, or their known associates; and individuals from high risk countries, as designated by the Financial Action Task Force. We reserve the right to apply Enhanced Due Diligence to anyone that we consider a high risk individual. For the purposes of these terms, we refer to the definitions as stated by EU Directive 2015/849.

Documents used to verify the identity information of high risk persons include, but are not limited to: a copy of a valid identity card or passport; proof of address. We will inform the relevant customers that the Company may seek this additional identification information to verify their identity. If the customer refuses to provide such information, or appears to have provided intentionally misleading information, the Company will not open a new account and will consider closing any existing account. If the customer has been identified as participating in any unlawful activity, the Company will take appropriate steps to freeze the customer's account.

We reserve the right to deny access to our service where we deem appropriate, and for any reason, without informing you of our concerns. Use of our service remains solely at the discretion of Magebox Entertainment LTD.

By establishing an account with Magebox Entertainment LTD, you are consenting to, and acknowledging:

• The information you provided to open an account is true, accurate, current and complete. This information includes, but is not limited to, your name and your email address.

• You will not use the service for illegal purposes, including but not limited to:

  • The conversion or transfer of property, especially money, knowing that such property is derived from criminal activity
  • Concealing or disguising the illegal origin of property
  • Helping any person who is involved in the commission of such activity to evade legal consequences
  • Concealing the true nature, source, location, disposition, movement, or rights of ownership of property knowing that such property is derived from illegal acts.
  • The acquisition, possession, or use of property knowing that such property was derived from criminal activity
  • Participation in, association to commit, attempts to commit and aiding, abetting, facilitating and counseling the commission of any of the actions referred to above.

While using our platform, you accept that we may forward any particulars about your account activity and transactions, to regulatory or government authorities of their bodies if:

• We are obligated by law to do so; or
• We are of the opinion that such a disclosure may assist in the prevention of fraud, money laundering or other criminal or terrorist behavior.

By submitting any information to us, you are establishing your compliance to these terms. We suggest you review these terms in full before choosing to register an account. All information provided will be collected, stored and processed in accordance with our Privacy and Data Protection Policy.

Virtual Asset Anonymizing Services

Magebox Entertainment LTD does not accept funds transferred using, or via, Coin Mixing services. We reserve the right to deny use of our service for clients that intend to conduct transfers from exchanges that we consider to be engaged in, or linked with, high risk or illegal activities.

Monitoring Accounts for Suspicious Activity

We monitor all transactions and account activity for unusual size, volume, pattern or type of transactions, taking into account risk factors and red flags that are appropriate to our business. Where we have cause for concern, or are legally obligated to, we will report suspicious transactions to the relevant authorities. Furthermore, we may also file a voluntary SAR for any suspicious transactions that we believe are relevant to the possible violation of any law or regulation but that is not required to be reported by us under legislation.

Compliance with International Sanctions Regimes

We take all reasonable measures to ensure that we are compliant with the financial sanctions as stipulated by the US Office of Financial Control (OFAC), the UK Office of Financial Sanctions Implementation (OFSI), the European Union (EU) and the United Nations (UN). We take all reasonable measures to ensure that sanctioned individuals or companies are denied access to our platform.

We will apply all reasonable measures to detect any attempts to use our platform by sanctioned individuals or organizations; any attempts as such will be reported to the authorities as soon as reasonably practicable, and without undue delay. This may involve the suspension of accounts and services should it be discovered that connected entities are sanctioned or are attempting to avoid sanctions.

Transfer of Anti Money Laundering Information to Law Enforcement Agencies

To perform the duties arising from law, the FIU has the right to request information from Magebox Entertainment LTD. We are required to comply with any such demands, including any information subject to banking or business secrecy, within the time limit, which is indicated in the request.

In an individual case, the FIU may forward to the compliance officer data registered in the FIU to the required and sufficient extent for the purpose of taking joint AML/CFT measures or measures for prevention of related criminal offenses.

We take all reasonable measures to ensure that we are compliant with the financial sanctions as stipulated by the US Office of Financial Assets Control, the UK Office of Financial Sanctions Implementation, the European Union, and the United Nations. We take all reasonable measures to ensure that sanctioned individuals or companies are denied access to our platform.

Data Security

All data given by any user/customer will be kept secure, and will not be sold or given to anyone else. Only if forced by law, or to prevent money laundering, may data be shared with the AML-authority of the affected state.

https://dejen.com will follow all guidelines and rules of the data protection directive (officially Directive 95/46/EC).